February 8, 2021
Argentina and US agree to exchange country-by-country reports on large multinationals
Once the agreement enters into force, Argentina entities will not have to file country-by-country reports if their ultimate parent entities in the United States filed the reports. Taxpayers should continue to monitor the publication of the agreement as that will indicate when the agreement will enter into force.
The US Internal Revenue Service and the Argentine tax authorities (AFIP) have signed a competent authority agreement on Base Erosion and Profit Shifting (BEPS) Action 13.
Even though the text of the agreement is not yet available, it should allow the exchange of country-by-country reports required in Argentina by General Resolution (GR) 4,130/2017.
Once the agreement enters into force, Argentine entities with controlling ultimate parent entities in the United States should not file country-by-country reports in Argentina if the ultimate parent entity did so in the United States. Those Argentine entities will have to comply, however, with the rest of the GR 4,130/2017 requirements, such as the first and second notification.
As stated in GR 4,130/2017, an agreement only applies when published on the AFIP's website. As of this Tax Alert's publication date, the AFIP's website does not include the agreement. The publication of the agreement should include the agreement's entry into force date.
We will issue an additional Tax Alert as more information becomes available.